Home » VAP Audit Guidance Document Section 3 – Hazardous Substances (VAP C3.1)

VAP Audit Guidance Document Section 3 – Hazardous Substances (VAP C3.1)

“Chemical and other materials posing a hazard if released to the environment are to be identified and managed to ensure their safe handling, movement, storage, use, recycling or reuse and disposal.”

“C3.1 Hazardous substances including wastes are properly categorized, labeled, handled, stored, transported and disposed using government-approved and/or licensed vendors as per local laws.
Minimum requirements:

  • Site observation:
    • Hazardous substances are categorized, handled, stored and transported within the facility.
    • To control access or potential employee exposure methods such as segregation, secondary contained, ventilation, fire protection, appropriate storage cabinets,
      hazard signage and information (labels and MSDS), limited access,… have been implemented throughout the site”
  • “Document review:
    • Documented procedures for reception, storage, dispensing, use, return and disposal are available and adequate- A written program shall be established to track, review, and approve the use of all hazardous chemicals and shall obtain approvals for all new purchases of hazardous chemicals prior to use
    • Auditee shall ensure that its selection processes for all new hazardous chemicals include a thorough evaluation of less hazardous or non-hazardous alternatives.
    • Auditee shall maintain accurate chemical inventory records.
    • Inspection records of hazardous substances and their points of storage and use are maintained and complete.
    • Auditee shall implement a detailed chemical storage and handling procedures.
    • If any area of improvement is noted, a corrective action plan is in place, monitored and completed. If the corrective action plan is off track anions are taken to complete
      it within the assigned due date
    • Hazardous material information (labels and MSDS) is available at the points of use and storage in the language of the worker
    • Documents proving Auditee uses only vendors approved and/or licensed by the local regulatory authorities for transporting and disposing of hazardous waste.
  • Current copies of all hazardous waste vendor licenses and/or approvals are on file. A process to ensure the licenses are periodically reviewed and are current is in place.
    • “Copies of hazardous substances inventory, manifests arid shipping papers are maintained on file for last 3 years or the time period stipulated by local laws legal
      requirements. These may be related to:

      • Air emissions;
      • Process wastewater discharge;
      • Hazardous materials storage and use; and
      • Generation of hazardous waste.
  • Rating:
    • Priority: Hazardous substances (including wastes) are used, handled, stored or disposed of in
      a manner that could result in imminent loss of facility, life or create sever bodily damage.
    • ‘Major: Hazardous substances (including wastes) are used, handled, stored or disposed of in a
      systemic way but 2 or more minimum requirements are not implemented
    • ‘ Minor: Hazardous substances (including wastes) are used, handled, stored or disposed of in a
      systemic way but the documentation is incomplete
    • ‘ Not Applicable: No hazardous substances (including wastes) used or stored on site.
  • Remote verification: Yes”